I202506 LOC Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
September 12,2025
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to the Letter of Concern dated August 20,2025(Report#1202506)
Dear Mr.Brooks,
This letter is intended to address two(2)areas of concerns stemming from a field audit conducted by the Idaho
Public Utilities Commission(IPUC)on August 4-6,in the Idaho Falls district of Intermountain Gas Company(IGC)
pursuant of Chapter 601 Title,49,United States Code.
AREAS OF CONCERN
1. 49 CFR§192,605 Procedural manual for operations.maintenance.and emergencies.
General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for
conducting operations and maintenance activities and for emergency response.For transmission lines,the
manual must also include procedures for handling abnormal operations. This manual must be reviewed
and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year.
This manual must be prepared before operations of a pipeline system commence.Appropriate parts of the
manual must be kept at locations where operations and maintenance activities are conducted.
2. 49 CFR§192.481 Atmospheric corrosion control: Monitoring
(b) During inspections the operator must give particular attention to pipe at soil-to-air interfaces,under
thermal insulation,under disbanded coatings,at pipe supports,in splash zones,at deck penetrations,
an in spans over water.
(c) If atmospheric corrosion is found during an inspection,the operator must provide protection against
the corrosion as required by & 192.479.
(d) If atmospheric corrosion is found on a service line during the most recent inspection, then the
next inspection of that pipeline or portion of pipeline must be within 3 calendar years,but with
intervals not exceeding 39 months.
OPS 403 Atmospheric Corrosion Monitoring
2.INSPECTION CRITERIA
2.3.Inspect soil-to-air interface.Refer to In-Service Protective Coating Criteria Table.Visually examine
for evidence of coating damage and confirm it is properly bonded so that penetration of moisture between
the pipe and coating is prevented.
2.3.2.Protective coating(wrap)at soil-to-air-interface shall be above grade.
2.3.3. Steel risers without protective coating surrounded by concrete or other hard surface directly in
contact with metal, shall be identified as Hard Surface.
2.3.3.1.Paint is an acceptable protective coating on anodeless risers.
In-Service Protective Coatin_q Criteria Table
GOOD FAIR POOR
The protective coating protective coating that is
may shoe:slight thinning
The protective coating or pulling away from the Peeling, cracking,
shall be adhering to the pipe, but should not be disbonded,or is exposing
pipe and shows no cracked or peeling,or the metal substrate.
cracking or peeling. exposing the metal Includes facilities only
substrate. coaled with primer.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]•FAX:[phone]
3. VISUAL INSPECTION FOR ATMOSPHERIC CORROSION
3.1. Above ground steel pipe, meter sets, risers, piping in vaults, etc., shall be visually examine
for evidence of Atmospheric Corrosion. Equipment in vaults shall be inspected in the same
manner as above ground pipe.
External PiDe Condition Evaluation Criteria
Pressure Condition Criteria
Classification
•Low Pressure •Ranges from showing no trace of rust(e.g..opdation),
•Distribution Good corrosion pitting,or rust scale,to having some rust
Pressure spotting.bud no corrosion pitting or rust scale.
•Ranges from a light coating of rust to uniformly heavy
Fair coating of rust,no scaling,slight to shallow corrosion
pitting up to 40%wall loss may be present.
.Rust scaling or severe corrosion pitting(as opposed to
slight to shalow in-Fair),either of which is greater than
Poor 40%wall loss-
.Any anomaly or defect(e.g.,gouges,notches,grooves.
dents)that may impact the overall integrity and
serviceability of the pipe.
Findin2(s)•
IPUC Inspectors observed 48747-HPSS-67800 with pitting on the low-pressure side(anodeless riser)of
HPSS.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. The riser was replaced on September 3, 2025
(WO12335592).
3. 49 CFR§192.747 Valve maintenance: Distribution systems.
(a)Each valve,the use of which may be necessary for the safe operation of a distribution system,
must be checked and serviced at intervals not exceeding 15 months,but at lease once each
calendar year.
(b)Each operator must take prompt remedial action to correct any valve found inoperable,unless the
operator designates an alternative valve.
Finding(s)•
Valve 48747-VLV-29560 was designated as a two-man valve in Maximo.However,technicians were only
able to move the valve key a few inches with significant force.This raised a concern regarding the valve's
operability,particularly in emergency situations.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. IGC Field Operations personnel flushed, greased,
and operated the valve on September 8,2025 (WO12335687). The valve is operating correctly.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
�G��JG�c-[ti0�L
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company